Embed Size (px)
Citation preview
4/18/2018
1
Respirable Crystalline SilicaIts Not Just Dust!
What is silica?
One of the most
common
minerals on
Earth
Photos courtesy
PDPhoto.org
Silica is found in rock, soil, and sand
Photo:
CPWR
Photo courtesy PDPhoto.org
eLC
OS
H im
ages
Concern:3 forms of crystalline silica
Quartz—common, found in sand, gravel, clay,granite, sandstone andother rock
Cristobalite and Tridymite—less common, but more toxic to
workers
Photo: CPWR
These materials may contain silicao Asphalt
o Brick
o Cement
o Concrete
o Concrete block
o Drywall
o Fiber cement products (siding,
cladding panels)
o Grout
o Mortar
o Paints
o Plaster
o Refractory Mortar/Castables
o Refractory units
o Rock
o Roof tile (concrete)
o Sand
o Soil (fill dirt, top soil, soil w/fly ash
added)
o Stone (granite, limestone, quartzite,
sandstone, shale, slate, cultured, etc.)
o Stucco/EIFS
o Terrazzo
o Tile (clay and ceramic)
How can you find out if it contains silica?
Product label
Safety Data Sheet
Published data—online
Analyze a sample of the
material
4/18/2018
2
Silica Hazards
Why is silica a
hazard?
Size matters!“Respirable” silica is small enough to penetrate body’s natural defenses and get deep into your lungs
Crystalline
Silica Photo source: CDC
It’s 100 times
smaller than
ordinary beach
sandwikimedia
Silicosis
The respirable silica dustenters the lungs and causesthe formation of scar tissues,thus reducing the lungs'ability to take in oxygen.
Photo: OSHA
How Small is Small?
0 1
Meter (m)
0.01.001.000001
Millimeter (mm) Centimeter (cm)Micron (µm)
Human Hair
(80 – 120 µm)
Respirable Dust,
e.g., Lead, Silica &
Asbestos (<10 µm) A lower case 'o' when
printed in Times New
Roman size 10 (1mm).
o
1 cm1 m
Large Dog
What can it do to you?
o Silicosis
o Lung cancer
o Chronic obstructive pulmonary disease (COPD)
o Immune system effects
o Kidney effects
Are these effects Chronic or Acute?
4/18/2018
3
Silicosis Facts
✓Permanent
✓Irreversible
✓No cure
✓Worsens after exposure ends
✓Deadly
Preventing exposure is your best defense
Normal Lung Silicotic Lung
Photo: CDC
Stop Silicosis - 1938
The Hawk's Nest Tunnel Disaster—1930—700 to over 1000 deaths
o Inhalation of respirable crystalline silica particles has long been known to cause silicosis, a disabling, non-reversible and sometimes fatal lung disease
Putting it all togetherSilica is hazardous because:
Causes lung
disease, cancer,
even death
Silica dust
travels deep
into your lungs
Short-time
exposure to
large amounts
causes harm
Airborne
particles too
small to see
Long-time exposure
to small amounts
causes harmFound in many
construction
materials
Effects worse if
you also smoke
eLCOSH
images
When will I find dust?
o Manufacturing: Foundries, Abrasive blasting, Paint,
Glass, Concrete, Brick making, Plumbing fixtures,
Refractory, Mixing (dry), Grout and Caulking
o Construction: highway, masonry, concrete, rock
drilling, cleaning up
o Construction tasks: masonry saws, grinders, drills,
jackhammers and handheld powered chipping tools;
vehicle-mounted drilling rigs; milling; operating
crushing machines; and heavy equipment for
demolition.
eLCOSH
Images
OSHA Respirable Crystalline Silica (RCS) Rule
o Two standards:
o One for general industry and maritime
o One for construction
o Similar to other OSHA Substance Specific Health Standards
OSHA Respirable Crystalline Silica Permissible Exposure Levels (PELs)
Action Level = 25 micrograms per cubic meter of air
(25 µg/m3) calculated as 8-hour TWA
PEL = 50 micrograms per cubic meter of air
(50 µg/m3) averaged over an 8-hour day
What does that mean?
4/18/2018
4
Industry Standard, 29 CFR, 1910.1053
oDEFINITIONS – PARAGRAPH (B) OF THE STANDARD
oPERMISSIBLE EXPOSURE LIMIT (PEL) – PARAGRAPH (C)
oEXPOSURE ASSESSMENT – PARAGRAPH (D)
oREGULATED AREAS – PARAGRAPH (E) >PEL
oMETHODS OF COMPLIANCE – PARAGRAPH (F)
•Engineering and Work Practice Controls >PEL
•Written Exposure Control Plan All covered employers
oRESPIRATORY PROTECTION – PARAGRAPH (G) >PEL
oHOUSEKEEPING – PARAGRAPH (H) All covered employers, avoid certain practices
oMEDICAL SURVEILLANCE – PARAGRAPH (I) >PEL >30 days/year through 6/22/2020
then AL
oCOMMUNICATION OF HAZARDS – PARAGRAPH (J) All covered employers
oRECORDKEEPING – PARAGRAPH (K)
Construction Standard, 1926.1153
(a) Scope
(b) Definitions
(c) Specified exposure control methods (Table 1)
OR
(d) Alternative exposure control methods
(1) PEL
(2) Exposure Assessment
(3) Methods of Compliance
(e) Respiratory protection, Required by Table 1 or >PEL for Alternative
(f) Housekeeping, All covered employers avoid certain practices
(g) Written exposure control plan, All covered employers
(h) Medical surveillance, Wear a respirator ≥ 30 days/year
(i) Communication of silica hazards, All covered employers
(j) Recordkeeping
(k) Dates
Silica Sampling Personal Breathing Zone
• Crystalline silica: respirable fraction is of concern due to the health effectso Sample for respirable particulate
Exposure Assessment
Silica Sampling
OSHA PEL: 50 µg/m3 = 0.05 mg/m3
16.8 m3
Respirable silica dust equivalent to
<0.1% of a sweetener packet over
the course of an 8 hour workday
would exceed the OSHA PEL of
50 µg/m3.
RCS Standard– Scope
o All occupational exposures to respirable crystalline silica are covered, unless employee exposure will remain below 25 μg/m3 as an 8-hr TWA under any foreseeable conditions.
o The phrase “any foreseeable conditions” refers to situations that can reasonably be anticipated, for example, failure of engineering controls
o Therefore, employers who maintain exposures below 25 µg/m3
with engineering controls are covered.
4/18/2018
5
Silica Exposure Determination
o Objective Data
• Plumbers, carpenters, and electricians who have to drill a hole are exempted—<15 minutes
• Construction tasks exempted also includes pouring concrete or removing forms
o Performance Option
o Scheduled Monitoring Option—IH Monitoring
o Utilize Table 1, (Construction Only)
• Fully and properly implemented
• Do not have to assess employees’ silica exposure levels or keep employee exposures at or
below the permissible exposure limit (PEL)
RCS Exposure Assessment
o Initial assessment
• Not required if objective data of exposure <AL of 25 µg/m3
o Scheduled Monitoring option—Periodic IH moniting
• < AL Discontinue
• > AL < PEL – every six months
• > PEL – every 3 months
o Performance option – assess exposure for each employee sufficient to
characterize exposures
o Reassess
Performance Option
o Exposures assessed using any combination of air monitoring data or objective data sufficient to accurately characterize employee exposure to respirable crystalline silica
o Be able to demonstrate that employee exposures have been accurately characterized
o Reassess exposures whenever a change may reasonably be expected to result in new or higher exposures at or above the action level
Objective Data
o Includes air monitoring data from industry-wide surveys
or calculations based on the composition of a substance
o Demonstrates employee exposure associated with a
particular product or material or a specific process, task,
or activity
o Must reflect workplace conditions closely resembling or
with a higher exposure potential than the processes,
types of material, control methods, work practices, and
environmental conditions in the employer's current
operations
Employee Notification of Assessment Results
o Within 15 working days after completing an exposure assessment;
• Employer shall individually notify each affected employee in writing of the results.
• Employer can post results in appropriate location accessible to all affected employees.
• If exposures exceed the PEL, the employer shall describe in writing the corrective action
being taken to reduce exposures.
• Observation of monitoringo Affected employees or their designated reps have the option to observe the air
monitoring.
o Observers must comply with the PPE requirements of the area.
Roadmap for meeting the Construction Requirements
of the Respirable Crystalline Silica Standard
o Determine if the silica standard applies to your employees
• Not required if objective data of exposure <AL of 25 µg/m3
• Required if employees could be exposed to RCS at or above 25 µg/m3 as an 8-hour TWA under any foreseeable conditions, including the failure of engineering controls
o Choose to comply with the standard using either the: • Specified exposure control methods in Table 1, or
• The alternative methods of compliance
(similar to General Industry)
» Schedule Monitoring Option
» Performance Option
4/18/2018
6
Specified Exposure Control Methods (Table 1)
Construction
o For each employee engaged in a task identified on Table 1, the employer shall fully and properly implement the engineering controls, work practices, and respiratory protection specified for the task on Table 1
o Table 1 tells you exactly the Equipment/Task, Engineering and Work Practice Controls, and Respiratory Protection
o If you don’t do it exactly you must use schedule monitoring or performance options
Construction –
Specified Exposure Control Methods
• Table 1 in the construction standard matches 18 tasks with
effective dust control methods and, in some cases,
respirator requirements.
• Employers that fully and properly implement controls on
Table 1 do not have to:
o Comply with the PEL
o Conduct exposure assessments for employees engaged in those
tasks
Tasks from Table 1
o Handheld Power Sawso Handheld Grinderso Jackhammers o Handheld Powered Chipping
Toolso Handheld and Stand-Mounted
Drillso Stationary Masonry Sawso Walk-Behind Sawso Drivable Saws
o Handheld Grinders for Mortar Removal (Tuckpointing)
o Rig-Mounted Core Saws/Drillso Dowel Drilling & Vehicle Rigs
o Walk-Behind Milling Machines and Floor Grinders
o Drivable Milling Machines
o Crushing Machines
o Heavy Equipment (cab operated)
Example of a Table 1 Entry
Equipment
/ Task
Engineering and Work Practice
Control Methods
Required
Respiratory
Protection and
Minimum APF
≤ 4
hr/shift
> 4 hr/shift
Stationary
masonry
saws
Use saw equipped with integrated
water delivery system that
continuously feeds water to the
blade.
Operate and maintain tool in
accordance with manufacturer’s
instructions to minimize dust
emissions.
None None
Example of a Table 1 Entry
Equipment /
Task
Engineering and Work Practice
Control Methods
Required
Respiratory
Protection and
Minimum APF
≤ 4 hr/shift > 4 hr/shift
Handheld
power saws
(any blade
diameter)
Use saw equipped with integrated
water delivery system that
continuously feeds water to the
blade.
Operate and maintain tool in
accordance with manufacturers’
instruction to minimize dust
- When used outdoors
- When used indoors or in an
enclosed area
None
APF 10
APF 10
APF 10
Equipment /
Task
Engineering and Work Practice
Control Methods
Required
Respiratory
Protection and
Minimum APF
≤ 4 hr/shift > 4 hr/shift
(vii) Handheld
and stand-
mounted drills
(including
impact and
rotary
hammer drills)
Use drill equipped with commercially
available shroud or cowling with dust
collection system.
Operate and maintain tool in
accordance with manufacturer’s
instructions to minimize dust
emissions.
Dust collector must provide the air
flow recommended by the tool
manufacturer, or greater, and have a
filter with 99% or greater efficiency and
a filter-cleaning mechanism.
Use a HEPA-filtered vacuum when
cleaning holes.
None None
4/18/2018
7
Fully and Properly Implementing
Controls Specified on Table 1
• Presence of controls is not sufficient.
• Employers are required to ensure that:
o Controls are present and maintained
o Employees understand the proper use of those
controls and use them accordingly
Employees Engaged in Table 1
Tasks
• Employees are “engaged in the task” when
operating the listed equipment, assisting with
the task, or have some responsibility for the
completion of the task
• Employees are not “engaged in the task” if they
are only in the vicinity of a task
Alternative Exposure Control Methods
1926.1153 (d)Utilized for tasks not in Table 1—Compile a List!
or
Where the employer does not fully implement the engineering,
work practice or respiratory protection described in Table 1
Employers can choose between two options for assessing
exposures:
• The performance option; or
• The scheduled monitoring option.
(Similar to requirements of General Industry)
Controlling Hazards
How does your employer protect you?
Hierarchy of Controls
Requires a physical change to the
workplace
Requires worker to wear
something
Elimination/Substitution
Requires worker or employer to do something
Most
Effective
Least
Effective
4/18/2018
8
Engineering controls
oWet methods• Cutting
• Chipping
• Sawing
• Milling
• Grinding
Must be used per manufacturer’s requirements!!!
Photo: OSHA
Engineering Controls
o Local exhaust ventilation (LEV)• Vacuum
• Dust collection system
o Substitution
o Isolation
Photo: OSHA
Engineering Controls
Cutting block using water to
control the dust
Cutting block
without engineering controls
Engineering Controls (cont.)
Grinding using a vacuum
dust collector
Grinding without engineering
controls
Engineering Controls (cont.)
Jackhammer use with water
spray to control dust
Jackhammer use without
engineering controls
4/18/2018
9
Administrative controlso Move employees out of hazardous area
o Hold a job briefing
o Use awareness barricades
o Don’t eat, drink, smoke, or apply cosmetics while near silica dust—wash hands/face
Photo source: CDC
Respiratory Protection
o Use of respiratory protection must comply with
29 CFR 1910.134 Respiratory Protection Standard.
o Respiratory Protection is required:• Table I requirements
• Where exposures exceed the PEL during periods necessary to
install or implement feasible engineering and work practice controls.
• Where exposures exceed the PEL during tasks, such as certain maintenance and repair
tasks, for which engineering and work practice controls are not feasible.
• During tasks for which an employer has implemented all feasible engineering and work
practice controls and such controls are not sufficient to reduce exposures to or below the
PEL.
• During periods when the employee is in a regulated area.
What else is required by the Silica Standard?
o Written exposure control plan
o Housekeeping practices
o Medical exams
o Training
o Record retention
4/18/2018
10
Respirable Silica Exposure Control Plan
o Establish and implement a written exposure control plan that identifies tasks that involve exposure and methods used to protect workers, including procedures to restrict access to work areas where high exposures may occur;
Written Exposure Plan
Written Plan must contain the following:
❖Description of tasks in workplace that involveexposure to silica
❖Description of engineering controls, workpractices, & respiratory protection used to limitemployee exposure to silica for each task
❖Description of housekeeping measures used tolimit employee exposure to silica
❖Description for procedures limiting access torestricted areas
Written Exposure Plan
oAnnual Review of Plan; or as deemed
necessary
oAvailable to Employees or their designated
representatives
oDesignated person to inspect the job site,
materials & equipment to make updates to
the plan
Regulated Area / IndustryAccess Control Plan / Construction
Regulated Area (Mfg.)
o Exposure > PEL
o Demarcation
o Limit access
o Respirators provided
o Work clothing provided if gross
contamination potential
Written Access Control Plan (Construction)
o Competent person ID presence/location
o Procedures to notify and mark
o Inform other contractors
o Provisions to limit access
o Procedures to provide respirators
o PPE
o Annual review & update
o Available
Who is the Competent Person (only construction)?o Must be designated by the employer
o Can change job to job or day to day
o Make sure you know who it is at your job site
o Responsibilities include:• Regular and frequent inspections of the job site;
• Identify existing and foreseeable respirable crystalline silica hazards;
• Authorized to promptly eliminate or minimize silica hazards; and
• Has the knowledge and ability to implement the written exposure control plan
4/18/2018
11
Now – I should NOT see dust, but…
o If engineering controls are in place and dust is present…
o If the tool isn’t working properly…
Notify the Competent person.eLCOSH Images
Housekeepingo If it contributes to silica exposure
• e.g. – creates/suspends silica dust
o NO dry sweeping or brushing
o NO use of compressed air for cleaning surfaces or clothing
o So, what do we do now?• Wet sweeping and HEPA-filtered vacuums
• Compressed air with vacuum system
• Procedure during filter change/vacuum clean out may be needed
Photo source: elcosh
Medical Surveillanceo Construction: If you wear a respirator 30 or more
days/year for silica exposure
o Industry: >PEL >30 days/year through 6/22/2020
then ≥AL
o Exam includes:
-Medical/work history
-Physical exam
-Chest x-ray
-Pulmonary function test
-Tuberculosis test
o Physician provides written reports
Photo: wikimedia
Medical Surveillance – cont.
oInitial Exam- within 30 days of assignment or last 3 years if the exams were the same requirements.
oPeriodic Exams – every 3 years, or more frequent if recommended by PLHCP.
oInformation provided to the PLHCP
• Copy of the standard
• Description of employee’s former, current, anticipated duties related to silica exposures.
• Description of personal protective equipment to be used, including when and how long it is used.
• Information from records of employment-related medical exams previously provided to employee if
possible (within the control of the employer).
oPLHCP’s written medical reports
oEmployee gets full detail of health results
oEmployer gets a fit for work result
Employee Information & Training
oThe employer shall ensure that each employee covered by this section can
demonstrate knowledge and understanding of at least the following:
• Health hazards associated with silica exposure.
• Specific tasks in the workplace that could result in silica exposure.
• Specific measures the employer has implemented to protect employees from silica
exposures.
oEngineering Control
oWork Practices
oRespiratory Protection Used
• The contents of this section of the silica standard.
• The purpose and a description of the medical surveillance program required.
• The employer shall make a copy of this section readily available without cost to each
employee covered.
Recordkeeping
o Training
o Air monitoring data
o Objective Data
o Medical Surveillance
• 1910.1020
4/18/2018
12
Effective Dates
o Manufacturing
• June 23, 2018 Program Requirements
• June 23, 2020 – Medical Surveillance Requirements
• June 23, 2021 – Hydraulic Fracturing engineering controls
o Construction
• June 23, 2017 Program and Medical Requirementso September 28, 2017 (4/6/17 announcement)
• June 23, 2018 Laboratory Analysis Compliance
Guidance and Outreach
o Silica Rulemaking
Webpage:
www.osha.gov/silica
o Fact sheets
o FAQs
o Video
o Appendix B – Medical
Surveillance Guidelines
o Small Entity Compliance
Guide
• Industry
• Construction
